Free Motion to Continue - District Court of Connecticut - Connecticut

.. - Case 3:00-cv-0066gFD Document 55 Filed 12/1€%OO3 Page 1 of 2 I
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UNITED STATES DISTRICCT COURT I
DISTRICT OF CONNECTICUT
ZORAIDA SANTIAGO : I
Plaintiff
vs. : CIVIL NO. 300CV00662 (CFD), { rb I
DEPT. OF SOCIAL SERVICES, ET AL. .l =-— E ,.
Defendants, : DECEMBER 10, 2003 _ . _ ._ l~ T ‘ I =
DEFENDANTS’ UNOPPOSED MOTION FOR CONTINUANCE F';_ I . if -.». il ' I
The defendants hereby move for a continuance of the oral argument calendar if - Iii
presently scheduled for Dec. 15, 2003 at 2:00 p.m. Defendants have permission to
represent that the plaintiffs attorney agrees to continue the oral argument for the
following reasons. I
The undersigned has sent the employment release authorization to Hobart West
I Group and is attempting to receive W’2s from them with regard to employers the plaintiff
worked for tlnough their temporary agency. Receipt of such information may vitiate any
need for tax infomiation from the taxing authorities. In addition, the defendant has sent
out medical release authorizations to treating medical providers and is awaiting
disclosure of plaintiffs medical records from them. Furthermore, the undersigned is
implementing the court’s suggestion and has scheduled the plaintiffs deposition for
December 17, 2003. Information received from these sources may very well obviate the
. need to pursue the motion to dismiss, and portions of the motion to compel. Lastly, the
parties are about to enter negotiations for settlement at this time.

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_ "I ` · » Case 3:00-cv-00662-CFD Document 55 Filed 12/10/2003 Page 2 of 2 1
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DEENDANTS,
DEPT. OF SOCIAL SERVICES, etal.
RICHARD BLUMENTHAL
ATTORNEY GENERAL
BY: ‘
eth Z. Margulies
#08469 ;
Assistant Attorney General A
Office of the Attorney General
55 Elm Street
P.O. Box 120 1
\ Hanford, CT 06141-0120 1
Tel: 860-808-5340 1
1 Fax: 860-808-5383
CERTIFICATION
1 hereby certify that the foregoing defendants’ unopposed motion for continuance
was mailed this 10th day of December, 2003 to Atty. Marc L. Glenn, Law Office of W.
1 Martyn Philpot, Jr., 4009 Orange Street, New Haven, CT 06511-6406, tel. 203-624-4666, ‘
fax. 203-624-5050.
Beth Z. Margulies 1
Assistant Attorney G neral
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